SEC Company Response from AQUABOUNTY TECHNOLOGIES INC (AQB) (CIK 0001603978) (AQB) — Apr 25, 2018
AQUABOUNTY TECHNOLOGIES INC (AQB) (CIK 0001603978)
Date: April 25, 2018 · CIK: 0001603978 · Accession: 0001603978-18-000039
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CORRESP 1 filename1.htm Document AquaBounty Technologies, Inc. 2 Mill & Main Place, Suite 395 Maynard, MA 01754 April 25, 2018 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Justin Dobbie and J. Nolan McWilliams Re: AquaBounty Technologies, Inc. Acceleration Request for Registration Statement on Form S-3 File No. 333- 224184 Acceleration Request Requested Date: April 27, 2018 Requested Time: 4:00 p.m. Eastern time Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), AquaBounty Technologies, Inc. (the “Company”) hereby respectfully requests that the effective date of the above-referenced registration statement on Form S-1 (the “Registration Statement”) be accelerated to April 27, 2018, at 4:00 p.m., Eastern time, or as soon thereafter as practicable. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act. Once the Registration Statement is effective, please orally confirm the event with our counsel, Goodwin Procter LLP, by calling Michael J. Minahan at (617) 570-1021. We also respectfully request that a copy of the written order from the Securities and Exchange Commission (the “Commission”) verifying the effective time and date of the Registration Statement be sent to our counsel, Goodwin Procter LLP, Attention: Michael J. Minahan, by facsimile to (617) 801-8717. In connection with the foregoing, the Company hereby acknowledges the following: • should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; • the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and • the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. If you have any questions regarding this request, please contact Michael J. Minahan of Goodwin Procter LLP at (617) 570-1021. Sincerely, AQUABOUNTY TECHNOLOGIES, INC. By: /s/ Ronald L. Stotish Ronald L. Stotish President and CEO cc: Michael J. Minahan, Esq. (Goodwin Procter LLP) David Frank, Chief Financial Officer (AquaBounty Technologies, Inc.) Christopher Martin, Esq., General Counsel (AquaBounty Technologies, Inc.)